Sanctions and Export Control

Joint venture in energy sector in Russia – our lawyers assisted two major international oil companies in developing a sophisticated sanctions and export control compliance programme for their joint venture in Russia in the area of oil exploration and production. The work included developing a general compliance policy, as well as detailed procedural compliance documents, advice on due-diligence procedures for customers and suppliers, training of staff, reporting and record-keeping. The compliance programme was a crucial element for the launch of the clients’ joint venture, in the context of the international sanctions applied to Russia’s energy sector.

International dredging company – for many years our lawyers provided ongoing sanctions compliance advice to a leading international dredging company in projects worldwide. This often included navigating novel issues in the area of sanctions law, and providing prompt risk assessment and practical advise on business-critical projects for the client. The sanctions regimes covered by our advice included sanctions against Russia, Iran, Cuba, Syria and Sudan.

Banks and financial services companies – our team routinely advises major international banks, asset managers, investment funds, insurers and reinsurers, and other financial services providers on a broad range of sanctions-related matters. Our services to financial services clients include developing compliance policies and programmes, advising on compliance of individual transactions, assisting the clients in due diligence/KYC checks of customers and counterparties, designing and negotiating sanctions clauses for the clients’ financing covenants and other contracts, and strategic advice on compliance with the conflicting sanctions-related requirements of EU and US regulations (including advice on the EU Blocking Statute).

Consulting company and trading-house - the team provided sanctions compliance advice on a wide range of projects and transactions, with a focus on EU sanctions compliance aspects. In most cases, advice was also delivered on US political and regulatory risk, related to projects and trade with Iran. The team has gained extensive experience advising on the implementation of the Iran Nuclear Agreement (JCPOA).